The EPA and Tier3 Marketing
As the EPA moves forward with its Tier 3 program proposal affecting emissions and fuel standards, it
faces a significant challenge in getting stakeholders aboard. Among those directly affected are the Big
3 automotive manufactures, as well as other auto manufacturers building or selling cars in the US, as
well as the petrochemical industry. Getting these stakeholders on board will call on the EPA to engage in
some serious Tier3 marketing, an effort they are having limited success with thus far.
The program, as proposed, will mandate a variety of changes. Emmissions standards will become
stricter. New, performance-based testing methods will become mandatory. Gasoline specifications will
change, in particular the sulfur content must be lowered, and more general fuel specifications will also
become more demanding. Both Phillips 66 and the American Fuel & Petrochemical Manufacturers raised
the complexity of this range of changes in asking for additional time to review the proposed regulations
and provide commentary. While the EPA did comply with a short extension, it fell far short of the
The Petrochemical industry and oil industry in general take a dim view of regulation and wield powerful
lobbies. While getting buy-in from these industries might be fundamental to enacting the new
regulations, the EPA might find the legislature under pressure to draft legislature that takes much of
the bite out of the new program. If the EPA wants to avoid this outcome, it may need to find a more
effective Tier3 marketing strategy with the petrochemical industry.
The EPA may also find itself under fire from the automotive manufacturers and their related industries.
The changes to regulations will presumably mean changes to automotive design and manufacturing
processes. The battered automotive industry may find itself objecting to the proposed changes on
financial grounds and automotive workers might rally against the changes out of fear for their jobs.
Where the EPA is more likely to succeed in its Tier3 marketing efforts are with the public, who seem
to have lost patience with the idea of too big to fail, while embracing green principles and punishing
companies that refuse to give up the old model of zero concern for environmental impact. If the EPA
can continue to push the environmental benefits, as well as the improvement to public health and air
quality, while diminishing the inevitable, but hard to quantify, doom saying of corporate giants, it may
be able to quell opposition from the automotive and petrochemical industries.